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Rodegeb), one of respondent’s revenue agents, to examine the
joint returns that petitioner and Ms. Brodsky had filed for the
taxable years 1987 through 1989. Sometime after she began the
examination of those returns, Ms. Rodegeb commenced an examina-
tion of the joint return that petitioner and Ms. Brodsky had
filed for the taxable year 1990. Mr. Sutton represented peti-
tioner and Ms. Brodsky during the course of respondent’s examina-
tion of their joint returns for 1987 through 1990.
During her examination of the joint returns of petitioner
and Ms. Brodsky for 1987 through 1990, Ms. Rodegeb asked peti-
tioner to send her all of his records with respect to those
taxable years. In response to that request, petitioner provided
Ms. Rodegeb with only limited records consisting of certain bank
statements, certain purchase invoices, and certain canceled
checks. Petitioner did not provide Ms. Rodegeb with any books of
account, such as general ledgers, or other records with respect
to his income-producing activities (books and records) for the
taxable years 1987 through 1990 that she needed in order to
conduct the examination of those taxable years. Consequently,
Ms. Rodegeb issued summonses on behalf of respondent to the banks
at which petitioner had informed her he and/or Ms. Brodsky had
maintained accounts during 1987 through 1990.
Around October 8, 1991, Ms. Rodegeb held a conference
(October 1991 conference) with petitioner and Mr. Sutton at which
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